11 Step Checklist for Effective Conflicts of Interest Management

Conflicts of Interest Management Checklist

Following this eleven-step checklist can help Chief Compliance Officers maintain a high standard of integrity and transparency, ensuring conflicts of interest are effectively managed and mitigated.

1. Establish a Clear Policy
   Define what constitutes a conflict of interest specific to your organization’s operations and ethical standards.

2. Communicate the Policy
   Ensure all employees are aware of the conflicts of interest policy through regular training sessions and accessible documentation.

3. Annual Declarations
   Require employees to submit annual declarations of external interests that might conflict with their organizational duties.

4. Transaction-Specific Declarations
   Mandate immediate disclosure of specific situations that may present a conflict of interest as they arise.

5. Develop a Reporting Process
   Create an easy and confidential process for reporting potential conflicts of interest.

6. Assess Declarations
   Evaluate declarations to identify actual or potential conflicts of interest.

7. Implement Management Plans
   For each identified conflict, develop a management plan detailing how the conflict will be mitigated or managed.

8. Document Actions
   Keep detailed records of conflicts of interest and steps taken to manage them.

9. Monitor and Audit
   Regularly monitor compliance with the conflicts of interest policy and conduct audits to ensure declarations are complete and accurate.

10. Review and Update Policies
    Periodically review and update your conflicts of interest policy to adapt to new regulatory environment changes and challenges.

11. Use Tech as a Tool
    Utilize integrated GRC (Governance, Risk, Compliance) software to automate the monitoring, management, and reporting of conflicts of interest—streamlining workflows and ensuring real-time compliance.